Facts of the Case
The appellant, Commissioner of Central GST and
Central Excise, J&K Jammu, preferred the present Central Excise Appeal
before the High Court of Jammu & Kashmir and Ladakh challenging the order
in favour of K S Profiles, SIDCO Industrial Complex, Bari Brahmana, Jammu.
The High Court observed that the present appeal was
identical to several other Central Excise Appeals already decided by the Court
through its common judgment dated 23.05.2022 in CEA No. 10/2020
(leading case). The appellant failed to point out any distinguishing facts or
fresh legal grounds warranting reconsideration of the issue.
Issues
Involved
- Whether the present Central Excise Appeal involved any fresh legal
issue different from those already decided by the High Court.
- Whether the appeal deserved independent adjudication despite the
earlier binding judgment rendered in CEA No. 10/2020.
- Whether the appeal was liable to be dismissed on the principle of
judicial consistency and precedent.
Petitioner's
Arguments
The appellant challenged the impugned order by
filing the present appeal under the Central Excise Act.
The appellant sought consideration of the appeal by
the High Court against the respondent, requesting interference with the order
under challenge. However, no new legal or factual ground distinguishing the
matter from the earlier decided batch of appeals was brought before the Court.
Respondent's
Arguments
Although no detailed submissions of the respondent
have been recorded in the order, the respondent's case stood covered by the
earlier judgment dated 23.05.2022 rendered in CEA No. 10/2020 and
connected matters, which had already settled the controversy involved in the
present appeal.
Court Order
/ Findings
The High Court held that:
- The present appeal was identical to several earlier Central
Excise Appeals.
- The controversy had already been conclusively decided by the High
Court in its judgment dated 23.05.2022 in CEA No. 10/2020.
- The appellant failed to demonstrate any fresh ground requiring
reconsideration.
- Since the matter was squarely covered by the earlier binding
decision, there was no reason to take a different view.
- Accordingly, the appeal was dismissed on the same terms and
conditions laid down in the judgment dated 23.05.2022 passed in CEA
No. 10/2020 and connected appeals.
Important
Clarification
- A subsequent appeal involving identical facts and legal issues
cannot succeed in the absence of any fresh distinguishing ground.
- Courts ordinarily follow their own earlier binding decisions to
maintain judicial consistency.
- Mere filing of another appeal on an already settled issue does not
justify reopening the controversy.
- The judgment reinforces the doctrine of precedent and consistency
in tax litigation.
Sections
Involved
- Central Excise Act, 1944 (Appeal Provisions)
Link to
download the order -
https://www.mytaxexpert.co.in/uploads/1782981310_134compressed.pdf
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